On behalf of the German and European Rubber Industry we ask to NOT extend CBAM to polymers and organic chemicals. We are representing 220 companies, producing a wide range of industrial products within the EU, elastomers and organic chemicals being their core material. All European mobility, the construction sector, baby- and healthcare, food production as well as drinking water supply relies on our products.
WDK
wdk
Industry association · Germany · EU Transparency Register 847583214230-94
7
positions filed
in the 665 files tracked
7
legislative files
of 665 tracked
6
with a full position paper
attached to a submission
Counts here are a floor, never a total: they cover the 665 consultation files tracked so far (57,774 submissions, mostly 2021–26), so an organization's real filing history is larger, not smaller.
Who they are
Among the 1518 trade and business associations on this site, they rank #509 by legislative files engaged, a count of participation, not a measure of influence.
0.6
declared lobbying FTE
self-declared
€100K+
declared costs / yr (floor)
1
EP accreditations
as declared to the register
2014
in the register since
Declares membership of
- European Tyre and Rim Technical Organisation (www.etrto.org/Home)
- Global Platform for Sustainable Natural Rubber (www.gpsnr.org)
- International Rubber Study Group (www.rubberstudy.org)
- Arbeitsgemeinschaft Zulieferindustrie (https://argez.de/)
- Bündnis faire Energiewende (www.faire-energiewende.de/)
- Initiative pro AGB-Recht (http://www.pro-agb-recht.de/)
- Europäische Bewegung Deutschland (https://www.netzwerk-ebd.de/)
- Inititiative Fair Rubber e.V. (https://fairrubber.org/de/)
- Rabber Traders Association of Europe(www.rtae.org)
- International Institute of Synthetic Rubber Producers (iisrp.com)
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026).
- Register category
- Trade and business associations
- Registered as
- Wirtschaftsverband der deutschen Kautschukindustrie e.V. (wdk)
- Head office
- Frankfurt/Main, Germany
Self-declared to the EU Transparency Register (snapshot 14 Oct 2026); cost bands are floors, not audited totals. Reused under Commission Decision 2011/833/EU.
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Their record over time
wdk filed 7 positions between 19 Aug 2020 and 5 Dec 2025, across 7 of the 665 legislative files tracked here, attaching a full position paper 6 times.
2020 · 1 filed2022 · 3 filed2025 · 3 filed
What they argued
The German Rubber Industry Association (wdk) is the umbrella organisation of German manufacturers of tyres and technical elastomer products (TEE). It represents around 170 companies with around 73 000 employees and a total annual turnover of almost eleven billion euros.
Filed in German · English published by the European Commission
Wirtschaftsverband der deutschen Ref. Ares(2022)3632766 - 12/05/2022 Kautschukindustrie e.V. wdk views on Data Act and Access to invehicle data initiatives The tyre industry welcomes the publication of the Data Act proposal as it represents a horizontal, high-level, principle-based regulation aiming at deploying a cross-sectoral governance framework for data access and use in line with the spirit of European Data…
Opening of the attached position paper · the full paper is on the Commission’s record (source link above)
The German Rubber Manufacturers Association welcomes the approach to amend annex I of the regulation (EU) 2023/1115 to clarify existing ambiguities in the regulation in a legally binding manner and to introduce technical fixes to address its unintended negative effects on the sustainable use of resources. However, adjustments will have to be made to the draft amendment of annex I to achieve this.
wdk contribution to Call for Evidence for an Impact Assessment Measures aiming to reduce the presence in the environment of unintentionally released microplastics from tyres wdk welcomes the opportunity to provide its comments on the upcoming measures aimed at reducing the presence of unintentionally released microplastics.
he German Rubber Manufacturers Association wdk welcomes the opportunity to provide feedback on the initiative on the planned Advanced Materials Act. Rubbers and elastomers are materials that are essential for components that are indispensable for various sustainable and critical technologies. Rubber and elastomer materials are designed to meet the specific requirements of their respective application.
The Wdk supports the European Commission’s Chemicals Strategy for Sustainability and welcomes its intention to consolidate chemicals regulation both between different regulations, such as REACH and the Drinking Water Directive, and between Member States.
Filed in German · English published by the European Commission
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Turns up on the same files
Organizations that also filed on at least two of the same consultations. A shared interest in the same dossiers, not evidence of coordination, and we do not suggest any.
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